Serbia: Law on Centralized Records of Beneficial Owners

The main reasons for the adoption of the Law on Centralized Records of Beneficial Owners (Official Gazette of
Republic of Serbia no. 41/18) (the “Law”),
which started to apply from 8 June 2018, are the improvement of the existing
system and harmonization with the international standards in this area. The Law
regulates the establishment, content, basis of recording and the manner of
operation of the Centralized Records of Beneficial Owners of legal persons and
other entities registered in the Republic of Serbia, as well as other matters
of importance for recording the beneficial owners.

The Law applies to:

1. companies, other than public joint stock companies;

2. cooperatives;

3. branches of foreign companies;

4. trade associations and associations other than political parties, trade unions,
sports organizations and associations, churches and religious communities;

The Law does not apply to companies and institutions in which the Republic of Serbia, an autonomous province or a local self-government unit is
the only shareholder, or founder.

Centralized Records

Centralized Records is a public, unified, centralized, electronic database of natural persons that are the beneficial owners of the Registered
Entity, maintained by the Business Registers Agency (the “BRA”). The BRA shall establish the Centralized Records no later
than 31 December 2018.

Criminal offence and misdemeanour

Failure to comply with the Law shall be considered a criminal offence, punishable by up to 5 years of imprisonment, and misdemeanour, where a fine may
be imposed on the legal entity and responsible persons.

Obligations of the Registered Entities

According to the provisions of the Law, the Centralized Register should be established by the BRA by 31 December 2018,
while the statutory representatives of Registered Entities should register the
data on Beneficial Owners by 31 January
2019. Until the establishment
of the Central Register, all legal entities in question must determine their
Beneficial Owners and procure documents and data on them within the period of
thirty (30) days after the day when the Law comes into force, i.e. until 8 July
2018 at the latest.